ML20197B181
| ML20197B181 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/23/1986 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20197B152 | List: |
| References | |
| 50-321-86-11, 50-366-86-11, NUDOCS 8605120473 | |
| Download: ML20197B181 (10) | |
See also: IR 05000321/1986011
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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REGION ll
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101 MARIETTA STREET N.W.
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ATL ANTA. GEORGI A 30323
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Report Nos.: 50-321/86-11 and 50-366/86-11
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Licensee:
Georgia Power Company
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P. O. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-321 and 50-366
License Nos.:
Facility Name: Hatch 1 and 2
Inspection Co
M ch 24-27, 1986
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Inspecto :
J3 86
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Date Si ned
Approve by:
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8 -(e, Section Chief
Date Signed
'En ne ring Branch
D is on of Reactor Safety
SUMMARY
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Scope: This routine, announced inspection involved 33 inspector-hours on site in
the areas of licensee action on previous enforcement matters (Units 1 and 2);
inservice inspection (ISI) (Unit 1); and inspection followup items (Units 1 and
2).
Results:
One violation was identified - Failure to perform Section XI pressure
tests - Paragraph 5.c.(2)(a).
8605120473 860430
ADOCK 05000321
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REPORT DETAI:.S
1.
Persons Contacted
Licensee Employees
- H. C. Nix, Site General Manager
- T. V. Green . Deputy General Manager
D. S. Read, General Manager, Quality Assurance (QA)
- T. R. Powers, Manager of Engineering
- T. Setz, Manager of Maintenance
P. E. Fornel, Manager of QA
- L. Sumner, Manager of Operations
D. A. McCusker, Superintendent of Quality Control (QC)
J. Hadden, QC Supervisor
- T. L. Elton, Supervisor of Regulatory Compliance
0. M. Fraser, QA Audit Supervisor
- C. M. Dixon, Engineering Support Supervisor, QA
T. S. Huckaby, ISI Engineer
- C. R. Goodman, Senior Plant Engineer - Regulatory Compliance
P. Norris . Senior Plant Engineer
G. R. Brinson, Senior QC Specialist
R. K. Moxley, Associate QA Field Representative
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, mechanics, security force members and
office personnel.
Other Organizations
. M. Belford, Supervisor, Inspection Engineering, Southern Company
Services (SCS)
D. R. Graham, Senior Engineer, SCS
NRC Resident Inspectors
- P. Holmes-Ray, Senior Resident Inspector
G. N. Nejfelt, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on March 27, 1986, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting comments were received from the licensee.
(0 pen) Unresolved Item 321, 366/86-11-01, Performance of System Leakage
and Hydrostatic Tests Using Nuclear Heat - Paragraph 5.b.
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(0 pen) Violation 321, 366/86-11-02, Failure to Perform Section XI
Pressure Tests - Paragraph 5.c.(2)(a).
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(0 pen) Inspector Followup Item 321, 366/86-11-03, Review of Procedures
Addressing ASME Section XI VT Requirements - Paragraph 5.c.(2)(b).
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The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
(0 pen) Unresolved Item 321, 366/85-14-02, Resolution of Requirements for
Increase in Inspection Scope When Corrective Actions are Required for Pipe
Supports.
This item was opened to resolve questions relative to the
licensee's program for re-examination of problem supports and expansion of
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inspection scope when results of pipe support examinations require
corrective actions.
The licensee has revised procedur( 45QC-INS-001-OS to
cover scope expansion when problems are found.
In addition, the licensee
has reviewed past practices and found that Section XI has not been violated
in the area of scope expansion.
In the area of re-examination, the licensee
is. in the process of reviewing the Winter 1981 Addenda to the ASME
Section XI to revise procedure 45QC-INS-001.
For the current outage and
previous outages, the Winter of 1980 Addenda, which does not provide details
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for re-examination, was in effect.
Procedure 450C-INS-001 will be revised
prior to the next Unit 2 outage.
(Closed) Unresolved Item 321, 366/85-14-01, Clarification of Requirements for
This item was opened to resolve. differences in the
Technical Specification (TS) snubber program and the ASME Section XI
requirements.
The licensee submitted a ravised ISI program (See Georgia
Power Company letter NER-85-483, dated June 25, 1985) updating to the W81
addenda of ASME Section XI for the second 10-year interval.
In the revised
program, relief was requested to perfora _ snubber inspections in acco~rdance
with the TS program in lieu of ASME Section XI.
Also, the program for:the
first 10-year interval to the 1974 ASME Section XI, S75 addenda, contained
relief requests (requests 2.1.2 and 3.1.1) to use the Tech Spec Program in
lieu of ASME Section XI.
See NRC letter dated July 29, 1983, approving the
relief request for the 1974 Code.
(Closed) Violation 321/86-02-01
"3 lyn to Follow Procedure for Signoff of
Traveler Steps for IHSI.
Gec/g l Pa u- Company's letter of response
(SL-460), dated March 14, 1986, 9 s cet1 reviewed and determined to be
acceptable by Region II (RII). The inspector examined corrective actions as
stated in the letter of response and discussed the corrective actions with
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responsible licensee personnel.
In order to verify corrective action, the
inspector reviewed:
Management Memorandum MM-MGR-002-0186, dated January 15, 19S6
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Departmental Directive 86-06, dated February 10, 1986
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Nutech
travelers
for welds 1831-1RC-12AR-G-1, 1831-1RC-12AR-F-1,
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IB31-1RC-22AM-3BC-1, 1B31-1RC-12AR-K-1, 1831-1RC-28A-16,
IB31-1RC-28A-3, 1-G31-1RWCU-6-0VT-12, 1-G31-RWCU-6-0VT-10 and
1-G31-RWCU-6-0VT-11,
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
One new unresolved items identified during this inspection are
discussed in paragraph 5.b.
5.
Inservice Inspection - Review of. Procedures (730528) (Unit 1)
The inspector reviewed ISI procedures as indicated below to determine
whether procedures were consistent with regulatory requirements and licensee
commitments.
The applicable code is the ASME Boiler and Pressure Ves el
(B&PV) Code,Section XI, 1980 Edition, W80 Addenda.
The following plan documents govern the ISI:
" Modified First Ten-Year Inservice Examination Plan for Class 1
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Components - Edwin I. Hatch Nuclear Plant Unit 1"
" Nondestructive Examination Outage Plan - Edwin I. Hatch Nuclear Plant
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Unit 1 - 1985 - Full Outage"
a.
Procedure Scope
The Nondestructive Examination Outage Plan and Associated NDE
procedures for the areas of examination listed below were examined to
determine whether the procedures were consistent with licensee TS
commitments and specified the examination category, method of
examination and extent of examination:
Stainless Steel Components
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- Reactor Pressure Vessel Shell and Head Welds
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High' Pressure Coolant Inject System Welds
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b.
Reactor Vessel System Leakage and Hydrostatic Tests
Based on BWR Owners Group comments to a revision to Regulatory
. Guide (RG) 1.99, questions have been raised relative to the method used
at plant Hatch to obtain Section XI system leakage and hydrostatic test
pressures and temperatures for reactor vessel tests.
Hatch performs
both tests (system leakage and hydrostatic) using nuclear heat during
startup at operating pressures and temperatures.
Questions have been
raised relative to use of this method based on the fact that under
operating pressures and temperatures, any leak would be a steam leak
rather than a water leak which would normally da expected from a
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hydrostatic test.
Other questions center around whether ASME
Section XI requirements are being met.
Most other BWR utilities use
methods other than nuclear heat to obtain required pressures and
temperatures.
During the current inspection, the inspector reviewed with the licensee
their practices . relative to the above question including procedures,
code requirements and reasons for their method of testing.
The applicable procedure is plant procedure 421T-TET-001-05,
Revision 1, Pressure Testing of Piping and Components.
This is a
general procedure used for all pressure testing.
The procedure
provides administrative controls, a " fill-in-the-blank," " Pressure Test
Specification," and a " Pressure Test Data Sheet."
The applicable code is the ASME B&PV Code,Section XI,1980 Edition,
W80 Addenda.
Article IWB-5000 of Section XI requires a system leakage
test after each refueling outage and a system hydrostatic test at the
end of each interval (ten years). Note 5 to table IWB-2500-1 requires
that the system leakage test be performed prior to " plant startup".
The licensee has interpreted " plant startup" to mean " roll" of the
turbine.
The ASME Code does not provide a definition of " plant
startup."
If the TS definition of startup is used, startup would be
when the reactor is taken critical.
If this definition is used, Note 5
of table IWB-2500-1 of Section XI cannot be met using nuclear heat for
obtaining pressure and temperature.
The main reason the licensee gave for performing the test using nuclear
heat was that they considered it safer for the reactor vessel since
performing the test under these conditions would result in pressure and
temperature further to the right of the pressure / temperature curve.
The licensee also noted that performing the test under conditions other
than nuclear heat would require gagging the safety relief valves with
fuel in the vessel which they considered to be undesirable.
Based on BWR Owner's Group comments to RG 1.99, Georgia Power Company,
by letter, dated November 11, 1986, requested SCS to evaluate the
acceptability of using nuclear heat for hydrostatic testing.
At the
time of the inspection, SCS was still evaluating the question.
Pending resolution of the question relative to the ASME Code
requirement / intent for performing the reactor vessel system leakage
test and/or hydrostatic test prior to " plant startup", Unresolved Item
321, 366/86-11-01, Performance of System Leakage and Hydrostatic Tests
Using Nuclear Heat, is identified.
c.
Pressure Testing Program
In the process of reviewing the reactor pressure vessel leakage and
hydrostatic test requirements, the inspector made a general review of
the Hatch program for pressure testing of ASME Class 1, 2 and 3
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components and piping to ASME Section XI as detailed below:
(1) Requirements
In general,Section XI requires:
System leakage test follexing opening and reclosing
Class 1
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of a component after each refueling outage
System hydrostatic test during plant shutdown near
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the end of each inspection interval (ten years)
Class 2
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System pressure test during system functional test
of systems not required to operate during normal
reactor operation - each inspection period
-(40 months)
System hydrostatic test during plant shutdown near
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the end of each inspection interval (ten years)
System inservice test at operating pressure
Class 3
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(categories DA and DC) - each inspection period
(40 months)
System pressure test during _ functional testing
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(category DB) - each inspection period (40 months)
System hydrostatic test near the end of each
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interval (ten years)
The Section XI requirements and the test boundaries are identified
in the Hatch Ten-Year Examination Plans.
The only procedure for
implementing the Ten-Year Plans is procedure 42IT-TET-001-0S, a
general procedure for performing all pressure tests.
Prior to the
current outage, there was no formal document identifying the
required tests for each outage.
For the current Unit 1 outage,
the required hydrostatic tests are listed in the Nondestructive
Examination Outage Plan.
(2) Problems Identified
The following problems were identified during the above review:
(a) There are no formal implementing procedures for scheduling
and tracking ASME Section XI pressure tests with exception of
the hydrostatic tests listed in the current Unit 1 Inservice
Examination Outage Plan.
Discussions with licensee and SCS
personnel revealed that in the past, the scheduling and
tracking have been on informal lists.
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Based on discussions with licensee and SCS personnel, lack of
implementing scheduling and tracking procedures has resulted
in Class 3 and possibly some Class 2, 40 month pressure tests
not being performed.
The licensee pointed out that some of
the tests were probably performed in the process of
performing other tests.
However, it is not clear for these
cases that VT-2 qualified examiners were used as required by
The failure to have implementing procedures is in violation,
The failure to perform required Section XI tests
is in violation of 10 CFR 50.55(a).
This violation is
identified as 321,366/86-11-02, Failure to Perform Section XI
Pressure Tests.
(b)
In reviewing procedure 42IT-TET-001-0S, the inspector noted
that the procedure did not reference a procedure for the
required VT-2 inspection.
The procedure only specifies a QC
walkdown and inspection for leakage without details or
reference to VT-2.
Discussion with licensee personnel
revealed that personnel performing the walkdown are qualified
to VT-2 requirements.
However, no procedure exist detailing
the code requirements for a VT-2 inspection.
During investigation of this finding, the inspector found
that site QA had an open audit finding (audit 85-ISI-02,
finding 85-ISI-2/165) identifying the fact that procedures do
not address VT-1, VT-2, VT-3 and VT-4 requirements of ASME
Section XI.
Pending review of the QA audit finding
corrective actions, Inspector Followup Item 321, 366/86-11-03,
Review of Procedures Addressing ASME Section XI VT
Requirements, is identified.
Within the areas inspected, no violations, except as noted in
paragraph (2)(a), or deviations were identified.
6.
Inservice Inspection - Observation of Work and Work Activities (737538)
(Unit 1)
The inspector observed the ISI activities described below to determine
whether these activities were being performed in accordance with regulatory
requirements and licensee procedures.
See paragraph 5 above for the
applicable code.
Since the ISI work for the current outage was essentially complete and no
work was in process for observation, the following records were reviewed in
lieu of work observation:
a.
Magnetic particle (MT) inspection records for the following welds were
reviewed:
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1821-1MS-24A-8PS-B-1
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IB21-1MS-24A-8PS-B-2
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1X13A-RHR-3
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The records were reviewed in the areas of:
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Availability of and compliance with approved NDE procedures
Use of knowledgeable NDE personnel
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Use of NDE personnel qualified to the proper level
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Recording of inspection results
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Examination method
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Contrast of dry powder particle color with background and
surface temperature
Examination overlap and directions
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Pole spacing and lifting power for yoke method
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Acceptance criteria
b.
Liquid Penetrant (PT) inspection records for the following welds were
reviewed:
SA-PL-1
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SA-PL-2
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IB31-1RC-12AR-K-3
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The records were reviewed in the areas of:
Availability of and compliance with approved NDE procedures
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Use of knowledgeable NDE personnel
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Use of NDE personnel qualified to the proper level
Recording of inspection results
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Method consistent with procedure
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Penetrant materials consistent with ASME Code materials
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Surface preparation
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Drying time following surface cleaning
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Penetrant application and penetration time
Examination surface temperature
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Penetrant removal
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Drying of surface prior to developing
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Developer type, application, and time interval after penetrant
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removal
Time interval between developer application and evaluation
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Evaluation technique
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Reporting examination results
Within the areas inspected, no violations or deviations were identified.
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7.
Inservice Inspection - Data Review and Evaluation (737558) (Unit 1)
The inspector reviewed the ISI NDE records indicated below for the current
'ISI to determine whether the records were consistent with regulatory
requirements and licensee procedures.
See paragraph 5 above for the
applicable code.
NDE records for the following pipe welds were reviewed:
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1G31-1RWCV-6-D-20: UT (45 , 60 )
1G31-1RWCU-6-D-16: UT (45 , 60 )
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1E11-1RHR-208-D-1BC: UT (60')
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1E11-1RHR-20B-D-1: UT (45 , 60 )
The records were reviewed in the areas of:
Calibration data sheets
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Proper recording of recordable indications
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Evaluation of examination data by a Level II or Level III examiner
Evaluation of data complies with applicable procedures
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Evaluction of indications complies with applicable procedures
Within the area inspected, no violations or deviations were identified.
8.
Inspector Followup Items (927008) (Units 1 and 2)
a.
(0 pen) Inspector Followup Item 321, 366/85-26-01, Examination of New
Welding Program.
The inspector reviewed the status of development and
issue of the new welding program.
Based on review of interoffice GPC
correspondence LR-ENG-029-0286, completion and issue of the new program
has been delayed. As noted in RII report 50-321, 366/85-26, the program
was to be implemented by March 31, 1986.
The first draf t of the
program was completed by December 1,1985.
Due to Unit 1 outage
demands, personnel were not available to complete review and issue of
the program.
Therefore, procedure 42SP-MNT-001-0S, Temporary Welding
Controls, was issued for the Unit 1 outage. Completion of the welding
program is estimated to be eight weeks after unit 1 startup,
b.
(Closed) Inspector Followup Items 321, 366/85-14-03, Clarification of
Procedures for ISI Inspection of Pipe Supperts.
Licensee procedures
have been clarified and revised in the six areas identified in the
inspector followup item.
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c.
(0 pen) Inspector Followup Item 321, .66/85-14-04, Update of ISI Plan
Pipe Support Sketches to Reflect Latest Design Information. This item
identified a problem with sketches for ISI of supports not being
updated to reflect the latest design information.
As noted in RII
report 50-321, 366/85-14, QA audit 85-ISI-1 identified the identical
finding.
Prior to the Unit 1 outage, the licensee walked down all
accessible systems and compared existing support sketches with all
design change information (IEB 79-14, DCR, etc.).
During the outage,
inaccessible systems were walked down for the same purpose.
Sketches
were or will be updated as necessary.
The same procedure will be
followed for Unit 2 prior to and during the next outage.
During investigation of this problem, the licensee found that there is
a possibility that design change information, other than for supports,
may not have been incorporated into the ISI program since 1980 when the
ISI contract was changed from Southwest Research to SCS.
Another
change that may have influenced the problem was a change in AE.
To
determine extent of the problem, all DCRs since February 1980, are
being reviewed for ISI impact.
In addition, procedures are being
changed to insure that DCRs that impact ISR are factored into ISI
requirements.
SCS is assigning a permanent engineer at the site for
review of DCRs that affect ISI and to take action to include changes in
the ISI program.
d.
(Closed) Inspector Followup Item 321/85-35-04, Review of ISI Inspection
Plans to Insure That Ten-Year Requirements are Met.
The inspector
reviewed deviations 008 through 016 to the NDE Outage Plan and
deviations 002 and 003 to the Modified First Ten-Year Plan and found
that all items identified in this inspector followup items had been
corrected.
The deviations also include items identified in SCS's
review of the plans.
In addition, the inspector reviewed SCS
memorandum, dated March 25, 1986, indicating that their review had been
completed and all errors corrected.
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